Page 1 of 3 

This working document was prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in 

discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final 

NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents 

preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and 

redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

NIOSH Response to Sanford Cohen & 

Associates Review Comments on 

Appendix BB Revision 3

Response Paper 

National Institute for Occupational Safety and Health

Division of Compensation Analysis and Support 

April 6, 2017 

By David Allen

Reviewed by James W. Neton, Ph.D., CHP 
Response Paper Response to Review of Appendix BB

Page 2 of 3 

This working document was prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in 

discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final 

NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents 

preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and 

redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Background 

A review by Sanford Cohen and Associates (SC&A) of revision 1 of Battelle-TBD-6000 

Appendix BB (General Steel Industries) resulted in 10 findings. A resolution to each of these 

findings was reached in the TBD-6000 Work Group of the Advisory Board. Some of those 

resolutions required a revision to Appendix BB which was accomplished with revision 2. SC&A 

was then tasked to review revision 2 to determine if the agreed to resolutions had been included. 

The SC&A review of revision 2, dated September 6, 2016, found that 8 of the 10 findings had 

been resolved. 

NIOSH’s response to this review on November 4, 2016, noted that minor changes to revision 2 

would be necessary. A description of the proposed changes were provided in the last page of 

NIOSH’s response. During a work group meeting on December 14, 2017, NIOSH’s proposed 

changes were agreed to, with the exception that the neutron energy range described in the 

proposed resolution would be changed to <10 keV. 

Revision 3 of Appendix BB was issued February 9, 2017, and SC&A was tasked with reviewing 

it to identify any questions or concerns regarding the resolution of issues. An email from SC&A 

on February 23, 2017, (Attachment A) indicated all but one of the substantive issues had been 

addressed. The one issue was that the neutron dose was not identified as ambient dose 

equivalent, which is referred to as H*(10). 

Response

While we agree it would be better to specifically identify neutron dose as H*(10), it is not 

necessary to specify every aspect of dose reconstruction within the Appendix. When information 

is lacking, the dose reconstructor will go to the subject matter export or choose the favorable 

option. In this case, both would result in using H*(10) DCFs. The H*(10) specification has not 

been in the Appendix in the past and the dose reconstructors have been using H*(10) as noted by 

SC&As review of PER-57. 

Therefore, a revision to the Appendix does not appear to be warranted based solely on this issue 

raised by SC&A. The ambient dose equivalent specification, however, will be included in any 

future revision. 
Response Paper Response to Review of Appendix BB

Page 3 of 3 

This working document was prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in 

discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final 

NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents 

preliminary positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and 

redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Attachment A

SC&A review of Appendix BB revision 3. 

Sent: Thursday, February 23, 2017 4:58 PM

Subject: Re: Preliminary review - Battelle-TBD-6000 Appendix BB - General Steel Indust...

Ted and Paul,

I have performed a review of Appendix BB, Revision 3, including a detailed comparison to Revision 2. All 

but one of the substantive issues that can have an impact on future DRs of GSI workers have been 

addressed. The outstanding issue is the failure to identify the neutron doses in Tables 5, 6, 8, and

9 as ambient dose equivalents (H*[10]). Absent such information, a dose reconstructor could 

erroneously assume that these are deep dose equivalents (Hp,slab[10]), for which DCFs are also listed in 

OCAS-IG-001. These latter DCFs are significantly lower for every organ listed. 

I note that NIOSH did not address the observations in our review of Revision 2, communicated in our 

memo of September 6, 2016. 

Bob 

Robert Anigstein, Ph.D.,

Task Manager

S. Cohen & Associates (SC&A, Inc.), Technical Support Contractor to Advisory Board on Radiation and 

Worker Health/NIOSH Centers for Disease Control and Prevention